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Federal Register / Vol. 86, No. 233 / Wednesday, December 8, 2021 / Proposed Rules
Estimated Number of Respondents:
Based on information provided by the SEC, FinCEN estimates that at least 8,884 entities would be obligated to make initial reports when the proposed rule would come into effect.297
Assuming that these entities file initial reports in Year 1, the estimated number of initial reports in Year 1 is 8,884. In years after this period, FinCEN
estimates that the number of entities required to file reports would be approximately 1,108.298 To estimate the number of updated reports per year, FinCEN used the same methodology explained in the BOI report estimate section to calculate, and then total, monthly updates. However, FinCEN did not account for differing numbers of beneficial owners per report, given the requirement is to report one beneficial owner. This analysis estimated 810
updates in Year 1 and 1,768 in Year 2
and beyond.
Estimated Time per Respondent: The information required to be reported to
FinCEN is basic information that reporting companies would have access to as part of conducting their business.
In addition, this requirement is likely less costly than the prior BOI reporting requirement because it only requires the identification and reporting of one beneficial owner with substantial control not ownership. Therefore, FinCEN estimates the burden of the reporting the report as 40 minutes per response 10 minutes to read the form and understand the requirement, 20
minutes to identify and collect information about beneficial owners, 10
minutes to fill out and file the report and attach a scanned copy of an acceptable identification document.
FinCEN estimates the burden of updating or correcting such reports as 20 minutes per update 10 minutes to identify and collect information about beneficial owners and 10 minutes to fill out and file update.
Estimated Total Reporting Burden Hours: FinCEN estimates the total
burden hours for Year 1 to be 5,923
hours.299 After this period, FinCEN
estimates the annual burden hours to be 739 hours.300 FinCEN estimates that the burden hours of updating reports would be 270 in Year 1,301 and 589 in Year 2
and beyond.302
Estimated Total Reporting Cost: To estimate the average cost, FinCEN used the May 2020 fully loaded wage rate of $38.44 per hour for all employees. The estimated total cost for initial reports in Year 1 is $227,663.75.303 After this period, FinCEN estimates the annual cost to be $28,391.05.304 FinCEN
estimates that the cost of updating reports would be $10,381.80 in Year 1 305 and $22,651.20 in Year 2 and beyond.306
iv. Total Burden and Cost The following table totals the burden and cost estimated in the prior sections.

TABLE 6TOTAL BURDEN AND COST
Information collection
Count of reports
Burden hours
Cost
Year 1
Initial BOI reports
Updates for BOI
Initial identifier applications
Updates for identifiers
Initial foreign pooled investment vehicle reports
Updates for foreign pooled investment vehicles

25,873,739
5,228,785
258,737
10,652
8,884
810

30,186,029
2,614,392
86,246
1,775
5,923
270

Totals

31,381,608

32,894,635

Initial BOI reports
Updates for BOI
Initial identifier applications
Updates for identifiers
Initial foreign pooled investment vehicle reports
Updates for foreign pooled investment vehicles

3,226,613
11,408,257
32,266
23,241
1,108
1,768

3,764,381
5,704,129
10,755
3,874
739
589

Totals

14,693,252

9,484,467

$1,160,332,854.17
307 100,495,669.61

3,315,236.73
68,243.57
227,663.75
10,381.80
$1,264,450,049.62

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Year 2 and Beyond
The following table shows a summary of total cost over ten years. FinCEN is selecting the time period of ten years, a relatively short time period given that the requirement is permanent. This is because FinCEN cannot predict how the burden and cost of compliance may change after it is widely adopted by reporting companies. Please note, there
are no non-labor costs associated with this collection of information because FinCEN assumes that active businesses already have the necessary equipment and tools to comply with the proposed regulatory requirements.

297 As of June 30, 2021, registered investment advisers reported 5,671 pooled investment vehicle clients registered with a foreign financial regulatory authority and venture capital fund advisers reported 3,213 advised private funds registered with a foreign financial regulatory authority. These two counts total 8,884. However, this estimate may not account for foreign pooled investment vehicles advised by banks, credit unions, or broker-dealers.
FinCEN requests any available information on estimates of foreign pooled investment vehicles advised by such entities.

298 FinCEN calculated the estimated foreign pooled investment vehicle filers per year 8,884 by the ratio of estimated new entities to total entities based on the IACA data analysis above 3,771,993.58/30,247,071.10.
299 8,884 40/60.
300 1,108 40/60.
301 810 20/60.
302 1,768 20/60.
303 5,923 $38.44. While this calculation equals $227,680.12, FinCENs model includes decimal points that result in the total of $227,663.75.

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$144,700,558.43
308 $219,263,279.14

413,430.17
148,895.06
28,391.05
22,651.20
364,577,205.05

TABLE 7TOTAL COSTS OVER TEN
YEARS
Year Year Year Year Year
1 2
3 4

Total cost $1,264,450,049.62
364,577,205.05
364,577,205.05
364,577,205.05

304 739 $38.44. While this calculation equals $28,407.16, FinCENs model includes decimal points that result in the total of $28,391.05.
305 270 $38.44. While this calculation equals $10,378.80, FinCENs model includes decimal points that result in the total of $10,381.80.
306 589 $38.44. While this calculation equals $22,641.16, FinCENs model includes decimal points that result in the total of $22,651.20.

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